James Wiley Accusation

SUPERIOR COURT OF NEW JERSEY
COUNTY OF HUDSON
LAW DIVISION - CRIMINAL
ACCUSATION NO. ^I'b - 12-
DOCKET NO.

STATE OF NEW JERSEY )

CRIMINAL ACTION

v. )

ACCUSATION

JAMES WILEY )

JAMES WILEY, having been charged with one count of Conspiracy (second degree), in
violation of N.J.S.A. 2C:5-2, and having in writing waived indictment and trial by jury, and
having requested to be tried upon Accusation before this Court, and said request having been
granted;

Attorney General Jeffrey S. Chiesa, for the State of New Jersey, by and through Deputy
Attorneys General Cynthia M. Vazquez and David M. Fritch, of the New Jersey Division of
Criminal Justice, alleges that:

COUNT ONE
(Conspiracy - Second Degree)
JAMES WILEY

and other persons whose identities are both known and unknown, who are co-conspirators but
who are not named as defendants herein, between on or about November 1, 2008 and on or about
February 29, 2012, at the Township of North Bergen, in the County of Hudson, elsewhere, and
within the jurisdiction of this Court did, with the purpose of promoting or facilitating the crime
of Official Misconduct, agree that:

A. One or more of them knowingly would engage in conduct which would constitute

the aforesaid crime, or

B. One or more of them knowingly would aid in the planning, solicitation or

commission of said crime, that is:

In that the said JAMES WILEY, a public servant, acting with the purpose to obtain a
benefit for himself or another, or to injure or deprive another of a benefit, in excess of $200, did
commit one or more acts relating to his office, but constituting unauthorized exercises of his
official functions, knowing that such acts were unauthorized or that he was committing them in
an unauthorized manner, and the said JAMES WILEY then and there being a public servant, to
wit: Superintendent of the Department of Public Works for the Township of North Bergen, New
Jersey, having thereby the official functions and duties, among others, to manage the resources
of the North Bergen Department of Public Works, including labor and salaries, for the benefit of
the citizens of North Bergen, to perform his duties in a legal and proper manner, to display good
faith, honesty and integrity, and to be impervious to corrupting influences, did knowingly misuse
labor paid for by the Township of North Bergen for the personal benefit of himself or another,
with the purpose to secure a benefit for himself or another in excess of $200, contrary to the
provisions of N.J.S.A. 2C:30-2.

In pursuance of the said conspiracy, JAMES WILEY committed the following OVERT
ACTS, among others:

1 . Signed and submitted paperwork required for the Township of North Bergen to
pay fifteen employees of the North Bergen Department of Public Works for providing sixty
hours of overtime labor on November 4, 2008, despite knowing that these individuals had not
performed work for the North Bergen Department of Public Works that day, but rather were sent

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to Bayonne, New Jersey, where they were utilized to support an election campaign by providing
campaign labor during the time that they were to be paid by the North Bergen Department of
Public Works, thereby causing the Township of North Bergen to expend funds in payment for
labor that it did not receive;

2. Signed and submitted paperwork required for the Township of North Bergen to
pay twenty six employees of the North Bergen Department of Public Works for twenty six hours
of overtime labor on May 12, 2009, despite knowing that these individuals had not performed
overtime work for the North Bergen Department of Public Works that day, when, in fact,
JAMES WILEY knew that this time was being submitted as fraudulent compensation for these
employees to go to Jersey City, New Jersey on May 12, 2009, where they were utilized to
support an election campaign by providing campaign labor, thereby causing the Township of
North Bergen to expend funds in payment for labor that it did not receive;

3. Signed and submitted paperwork required for the Township of North Bergen to
pay numerous employees of the North Bergen Department of Public Works for providing
overtime labor on November 2, 2010, despite knowing that these individuals had not performed
work for the North Bergen Department of Public Works that day, but rather were sent to Jersey
City, New Jersey, where they were utilized to support an election campaign by providing
campaign labor during the time that they were to be paid by the North Bergen Department of
Public Works, thereby causing the Township of North Bergen to expend funds in payment for
labor that it did not receive; x

4. Between on or about January of 2008 and January 21, 2012, signed and submitted
paperwork required for the Township of North Bergen to pay employees of the North Bergen
Department of Public Works for providing two hundred and seventy four hours of labor,

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including one hundred and fourteen hours paid as overtime labor, despite knowing that these
individuals had not performed work for the North Bergen Department of Public Works during
these hours, but rather were sent to JAMES WILEY'S residence, where they were utilized to
provide personal household labor during the time that they were to be paid by the North Bergen
Department of Public Works, thereby causing the Township of North Bergen to expend funds in
payment for labor that it did not receive;

All in violation of N.J.S.A. 2C:5-2, and against the peace of this State, the government
and dignity of the same.

JEFFREY S. CHIESA

Attorney General of New Jersey

By:

Deputy Attorney General

Dated: September 11, 2012

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